On June 22, 2026, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a new general license (Iran General License X or “GL X”) as the first step in implementing the US-Iran Memorandum of Understanding (“MOU”) to end recent hostilities in the Middle East. The MOU has not been formally or officially published by US Government agencies such as the State or Treasury Departments but its text has widely been reported and confirmed…
On June 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a suite of updated Venezuela-related general licenses (“GLs”) that slightly ease certain licensing conditions related to governing law and dispute resolution clauses in contracts involving the Government of Venezuela, Petróleos de Venezuela S.A. (“PdVSA”), CVG Compañía General de Minería de Venezuela CA (“Minerven”), or any entity in which PdVSA or Minerven owns, directly or indirectly, a 50% or…
On May 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 134C (“GL 134C”), further extending the temporary authorization for certain transactions involving crude oil and petroleum products of Russian Federation origin that were loaded onto vessels prior to a specified cutoff date. GL 134C replaces and supersedes General License No. 134B (“GL 134b”) in its entirety but replicates its substantive terms. As we previously reported,…
On May 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 58 (“GL 58”), authorizing transactions ordinarily incident to the provision of certain services in connection with potential debt restructuring of the Government of Venezuela. GL 58 provides a limited authorization for specified transactions, subject to conditions and exclusions, and reflects OFAC’s continued use of general licenses to relax US sanctions on Venezuela. Our prior blog…